Does WCAG 2.1 Replace 2.0? When Should You Adopt WCAG 2.1?

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This is the final post in a three-part series about WCAG 2.1. Previously, we covered WCAG 2.1 in AMP (Accessibility Management Platform) and WCAG 2.1: Exploring the New Success Criteria

WCAG IconWhen we informed our clients about the upcoming WCAG 2.1 standards, the first question was almost always, “What’s the deadline for adopting them?” The answer, however, is not as straightforward as for the Section 508 Refresh standards.

Level Access’s recommendation is to seriously consider adopting WCAG 2.1 Level A and AA when you are creating or updating your accessibility policy. Some of the criteria—in particular, related to non-text contrast—may impact the design of new assets. Adoption will likely be an iterative process that needs to start with new assets and then later changing existing assets (as needed). WCAG 2.1 requires testing and conformance to each responsive variation of a page (phone, tablet, desktop, etc.). In addition, it requires support for narrow width layouts (often experience on mobile) on the desktop to accommodate users with low vision. Because of this sites that have a separate mobile and desktop view (called adaptive sites) may need to provide a link between the views and the mobile view will have to be in the scope of conformance for testing. Because of the increased scope of variations of the site under WCAG 2.1 — WCAG 2.1 audits may require addition level of effort.

Thus, think about WCAG 2.1 as the future that you should be planning for in order to meet the needs of your customers and the future requirements of organizations you sell products and services to. Generally, if you are simply testing an existing product, there’s likely no legal/procurement need to target 2.1 conformance or move on it at this time. But there’s also no harm in using the latest guidelines since WCAG guidelines are backwards compatible and you’ll be creating a better user experience for people with disabilities.

WCAG 2.1 does not supersede or replace WCAG 2.0.

While WCAG 2.1 adds new success criteria, it does not replace or supersede 2.0. If you are mandated with WCAG 2.0 conformance, you can use the 2.1 guidelines as an alternate route to reach that goal. In fact, WCAG 2.1 is the current recommendation for those organizations looking to address accessibility through the adoption of W3C standards.

“WCAG 2.1 is the current recommendation for those organizations looking to address accessibility through the adoption of W3C standards.”

WCAG 2.1 is recommended for new or updated accessibility policies.

The W3C recommends that organizations adopt WCAG 2.1 when they are looking to update or create accessibility policies. In addition, some organizations may require WCAG 2.1 conformance from third parties and vendors. For these organizations, adherence to WCAG 2.1 is critical to ensure compliance with applicable requirements.

We have heard from a number of customers that they have decided to adopt WCAG 2.1 shortly, while others are taking additional time to adopt.

WCAG 2.1 is not required by government agencies or under Section 508.

At this time WCAG 2.1 is not required by the revised US Federal Section 508 standards. The US Access Board would need to start an official process to update the revised standards to reference the updated WCAG. This is a long process and is something the Access Board will have to consider, however, it is unlikely to occur. It is more likely that the US Access Board would pursue incorporation of the next major set of web accessibility standards which are expected from the W3C in around three years.

Some organizations planned for the future in their accessibility standards. For example, California’s government website requirements indicate that vendors can use WCAG 2.0 or the latest version of WCAG.

For those in the education space, we have heard some talk of institutions starting to look at adoption of WCAG 2.1. The University of Minnesota has adopted WCAG 2.1 as there digital accessibility standard. The timeline for adoption and updating procurement requirements will be lengthy. In addition, state institutions may have policies that are based on state accessibility requirements. Each state has their own time line for adoption of standards which may or may not include adoption of WCAG 2.1. Thus, it’s likely requirements will be inconsistent across educational institutions in the near term.

WCAG 2.1 will likely be needed to sell into some organizations.

There will be organizations that will be writing 2.1 into their procurement guidelines. For example, if an organization such as a bank or university adopts WCAG 2.1 as their procurement requirement, you will want to meet the 2.1 standards in order to be eligible for that contract. In these situations, the requirements will likely apply to new content and new sites rather than retrofitting older sites to WCAG 2.1.

The Voluntary Accessibility Product Template (VPAT) reporting format developed by ITI and which may be requested during procurement (especially in the public sector) is currently at version 2.1. Version 2.1 covers WCAG 2.0, Section 508 (revised 2017) and EN301549 1.1.2 standards. Although it is version 2.1 it does not yet cover WCAG 2.1.

WCAG 2.1 is being applied to European ICT standards as well.

WCAG 2.1 criteria is built into the latest update to the European ICT standards suitable for procurement EN 301-549 version 2.1.2. so organizations building new sites and apps for public sites in EU will need to be conformant for launch of sites a year from now (late 2019).

WCAG 2.1 is not widely referenced in demand letters or legal complaints (yet).

If your site or app is used in a place of public accommodation under the Americans with Disabilities Act (ADA), there is only one settlement (Alameda County, CA) and no decisions setting a precedent for WCAG 2.1. Thus, for ADA purposes, WCAG 2.1 is not yet widely being leveraged. However, it is likely that plaintiffs will start referencing WCAG 2.1 in demand letters and legal complaints, and that WCAG 2.1 will come up more often in settlements as part of what plaintiffs are asking for  – it’s just a matter of time.

Give Feedback on WCAG 2.1

Interested parties can provide feedback on WCAG 2.1 and related documents via the WCAG github issues page.

What’s Next for WCAG?

More work still remains to increase access to a wider range of content for more people with disabilities. There will be future updates that may come first in a WCAG 2.2 that builds on WCAG 2.1 or next as a whole new and renamed version of WCAG that may address broader issues such as user agent and authoring tool accessibility requirements and measures of conformance that include user testing. For more information on future plans for WCAG see the Silver Task force wiki page. The effort is called Silver because the periodic table symbol for Silver is AG – AG being the initialism for Accessibility Guidelines.

Helpful Resources

There are several informative documents that help users understand and test the WCAG success criteria. My favorite is the understanding WCAG 2.1 (editors draft) document. There is also the How to Meet WCAG document which has been updated for WCAG 2.1.

The What’s New in WCAG 2.1 from the W3C’s WAI provides some useful information including personas that help you understand how each success criteria applies to people with disabilities.

1 Comment

  • Mastermob
    September 21, 2018

    When a Web Technology is used in a way that is “accessibility supported,” it does not imply that the entire technology or all uses of the technology are supported. Most technologies, including HTML, lack support for at least one feature or use. Pages conform to WCAG only if the uses of the technology that are accessibility supported can be relied upon to meet WCAG requirements.

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